 Okay, the compliance enforcement advisory subcommittee to order today just I'll go through roll of news here. Looks like Ashley Reynolds is present and we've got from the board we've got. James Pepper and Kyle Harris. Any of the board members now in present? Nope. Just me today. Julie's watching actually. She just stepped out of her office. Julie Holberg board member. Okay. Julie Holberg will also be president from the NACPU Mark Foreman and Gina Cranwinkle and myself and other advisory subcommittee members. It looks like other subcommittees are joining us to help out as well. Chris Walsh, Siobhan Cotel, and we also have Jim Flanagan. And Skylar Ginesa I think is another guest today. Yes, Skylar. Skylar's from the division of the third department of clicker and lottery. And I think that covers everyone. We have one member of the public joining us on this lovely rainy Monday. Oh, great. I should do it. All right. All right. Thank you. Thank you everybody. This is the last scheduled meeting we have and after this we'll move more into an ad hoc basis. I think the conversations over the last month and a half have been really great. Really productive. I think it was wise for us to return to retail inspection security enforcement today. Skylar with the department of clicker and lottery is here. They've provided some insights to the board and to the subcommittee. And so I've asked Skylar to kind of give a rundown of their thoughts and how they typically conduct their business and how they look to do so. Adding this new market recognizing that, you know, as they reference in their letter, everybody's got a lot to learn how to do this the right way effectively and making sure we're educating first and foremost. After that, I think I just like to continue the conversation around transportation security. I think there was a lot of a lot of thoughts, a lot of perspectives that were shared at our last meeting. And I want to make sure that everybody has an opportunity to after the weekend to continue to share those thoughts. I'm kind of trying to figure out how to thread the needle on all these different perspectives and bring some of the conversation to the board level. So I just want to see if we can kind of find a way to, you know, do what we can to ensure that there's no diversion, that there's no theft and that things are secure while making sure that, you know, we're not overly burdening. Our small cultivators with certain requirements, we may ask of them retrofitting vehicles, so on and so forth. But it's a tall task, but one that I think I'm starting to see a good starting point for as we talk about this tiered structure. So with that introduction, Skyler, I can turn it over to you. I'm hoping you can kind of give an overview and then we can talk about how we perceive retail enforcement to really take shape here. And in the state of Vermont. Yeah, Kyle. Thank you so much for the introduction. Members of the board members of the second take the time over the opportunity. It was a can today. I apologize. I have my video off. I'm going to speech. They've been with I don't have the best internet for like Kyle said, I am here. And provide some perspectives that we were asked to make it provides the subcommittee in terms of retail security. Parallels that we have within the Department of liquor and law. And referencing a letter signed by our deputy commissioner. Let me just click overview of the document that we did just first three things are a bit of a preference. But before the subcommittee is first and foremost, we acknowledge that cannabis is a completely different substance than beverage alcohol and tobacco. One that remains illegal at the federal level. And we know that that's going to have some unique challenges. Additionally, my office compliance and enforcement being the law enforcement component of liquor and lottery. We're going to report. You know, we're not going to report to the subcommittee to be an expert. Secure physical security or sub. Lastly, our current regulatory structure for license establishments really only 10. All of those premises aside, what I would say we are the best at at the Department of liquor and lottery is triaging our regulatory structure based on a values approach. So as the board identifies and prioritizes its values. The regulations as promulgated by the board really reflect that to the subcommittee and cannabis control board. He's to have your regulatory. Hey, Skyler. Kyle. Yes. Yeah. You're coming through a little chapter. I know I know you're helping us out coming from overseas. What it makes sense for me to try and screen share your document and I can just kind of move us along in that way. We can save some of your bandwidth so we can we can get the substance of what you're saying without it having a big chop to it. Definitely. Give me one moment and I will pull up your voice any better. Yeah, no, I think it's a lot better if you're not screen sharing. Yeah, I think if we can just limit your bandwidth that would be or you know, not overly burdened some of your bandwidth that might be more productive. So give me one second. Understood. And my incoming video, which may help also. Yeah. Thanks, Kyle. The three graphics topics there at the top. The next section that the commissioners letter address it is nations that the board hasn't posed that has a nexus to site security or be very clear. Some of them are going to directly be very prescriptive regulations around site security. All of them are tangential and we put them to take into consideration there. I want to say is additionally relations down below our general regulations. As I've mentioned before this board, we strongly believe even with visible secure. We have a robust education workers. Because we've know we've learned time and time. That my programs and really strong data that there is a drawer. Back of training and increase incidences. So if you can. First of these products on the regularly promulgate or laws related to. It's going to be your I'm getting really numerous warnings. Can you hear me still Kyle? You're definitely a little choppy. Hopefully we find our stride here. So let's let's let's keep moving along seem we can get you to find your stride with bandwidth now we can we can open up for discussion and maybe. Yeah, rely less on you to speak and you know I know folks with the subcommittee may have. Been able to work through all this but any you know I know we've got some some folks that have. Some alcohol background I know Savannah and Chris do at least and their experiences and how we how we might look to kind of adopt what you're doing with currently with with cannabis coming in but. Let's keep trying to move along smaller and if it gets to the point where it's just feudal. We can pivot. Yeah please interject. Aside for probably useful information we sent Kyle would have been the document. Retail operations. I'm hoping that maybe you can pull that out. If not I can talk through it. That model is obviously very. It's model meaning those. There are 802 spirits liquor contractually entered with across the state. But in scope then our license. If you will the board is much more. So those contracts are entered into. And it has established much more specific. Around beating and prioritizing these responses to kids. Or the contract agency stores what you'll find in here. That each location is assessed using them. Mobile app. We send multiple eyes to go. This assessment to limit bias and to get the best picture of the establishment. We do receive on a on a point based scale. For a lottery board to again get a good understanding of the location that is applying for an 802 spirits. For the board to you know. The only of this is this location to. Be on this is very different. We treat our two agencies. Three bars and restaurants in the state. You know one word control state. Should housing this inventory is actually how. Security is fairly important to the form. Or it's taxpayer inventory that sits on these shelves so secure. For these types of license. Bars and restaurants that's. Security is less factored in certainly less person. The requirements to hold up first. So again that harkens. Approach to rating. Criteria for suitability for these establishments. Love to demo and show you the application that we use. We add its max but the app uses fairly configurable internally. What we would say is again while my department isn't. If you wouldn't report to me we are. And do have the mechanism to do field level analysis of these locations. To collect the data that would be the most meaningful. So you know level of security in terms of physical law. The. For that surveillance video things like. Video in place you know all of those things that the board would have to. Then wait in terms of importance we would have the ability to do. You know site assessments and provide that in. And the license application to allow the board who's ultimately going to be. Licensing authority into consideration when determining whether. Really hoping I haven't lost you all connection why. At least a little bit intelligible I'm happy. Talk a little bit more about the regulations that are tangentially. Related I'm hoping I'm a assistance. Thank you Skyler I think I was able to catch maybe sixty to seventy percent. Of what you said and that's no fault to you but just you know. The nature of how we're running teams meetings these days and you're in Europe. So I was like nine something on your calendar so. And then I was in New Zealand so hey. We're on three continents trying to figure this out. So I know I know I know Skyler's introduction was a little little choppy to know. Folded his own but but any opening thoughts on the documents that he sent. For anybody anybody want to kick us off. Thanks a lot. And it was helpful. Even though Skyler's audio was choppy it was helpful. I assume most of us probably read the documents beforehand. So you know kind of could tell what he was referencing when certain sentences were truncated. I thought the letter that Wendy and Skyler's beforehand. Was helpful in highlighting. The balance the balance that DLL has had to navigate and the same balance. CCB needs to navigate now. Of you know what's the right level of high touch versus low touch. Right now how in depth are you trying to be. And the letter highlights a couple of things that DLL has done pretty well when it comes to certain things that you know establishes that the licensee needs to do X Y or Z. But doesn't necessarily specify how they have to do it. These are the discussion. You know like the intentionally vague air back in there that was highlighted in the letter about you have to control your establishment and control the conduct of you know. Patreons after establishment doesn't say what that means. But it puts the onus on you to make sure that your place is not unruly and you don't have people getting the fist fights right. And so I think that that highlights well some of the things that it's helpful to make them explicit. But also helpful to put the onus on the licensee to figure out what that means for them in their business. So I thought that was a nice highlight in there that probably does transcend the barrier between alcohol cannabis. You have a very different font. Thanks Vaughn. David I work in enforcement. I'm going to pick on you for a second. Any thoughts. I can't really guarantee that my internet's any better than Scott. The most. Scholar's been mustache to you as a rock. I wanted this known in this house like I have a question about the failure rate for training which was at the very bottom of that letter. I like DLS educational approach as you can for regular that's very much a standard across the agencies. But how did you how do you come up with the post to train or these mandatory classes. How do you keep it interesting. And do you provide extra education for those who have a higher failure rate with enforcement. So I guess my question after all that potentially could be do you continue to educate those who perpetually fail. And at what level do you do enforcement. Yeah. Great questions. So first I would say the answer is. We do have mandate servers of beverage alcohol. They have to they have to renew that certification. So there is our laws. They change almost every legislative systems change of regular intervals. As the industry grows as the retail marketplace. Legislative. And I would assume that would be the same. So having that continual you know refresher training and say intervals. I think it's really going into that follow up training. Yes. It monitors our compliance rates very closely. People with knowledge. Our website displays licensees to its checks and follow up. Additionally typically when our board will mandate retraining for sellers and servers. I wouldn't want to call it a punitive measure but as a as a measure to endure issues that we see by the business. A mechanism that the board has levy in turn. So that's all. Thanks. Dave you get what you need to know. What if I have to do to answer that. I don't know. If that was a question to me I didn't quite I didn't quite catch that. Okay you might want to type it into the comments. While we're fighting some tech glitches on a Monday. Anybody else have any thoughts. Ingrid based on your background. Do you have any any thoughts on retail. Security enforcement inspection. Not at this time sorry I'm struggling to to follow some of the comments and such here. I can appreciate that. One of the pitfalls of teams is relying on the internet so actually I'll circle around to you any thoughts. I'm just curious I mean this is just a proposal but are we thinking there's going to be some sort of hybridized enforcement of DLL and ad or are we kind of still trying to figure out if that even makes sense to have folks overseeing. I think right now the board hasn't made any final decisions I think we're still looking for now that our market analysis has been turned over or recommendations have been turned over to the legislature. And it's seeing where we are from a proposal perspective from ag and from DLL this kind of starts painting a picture on DLL DLL is thinking about it from my perspective. And in our proposal to the legislature we do signal that we are hoping to bring some enforcement staff in house but we don't have there's a long way to go before the legislature. I think would include that in our budget for the next couple of years. So you know right now this is where where we're at and just trying to come up with a correct combination that gives consumers cultivators retailers and general public. Enough confidence that we have good partnerships with sister agencies to get the job done. I would imagine that retail right now where we're kind of thinking about this in this context of a retail enforcement. I think there could very well still be some consideration from the agency of agriculture there and also from a product safety perspective on the store shelf and shelf life security along those lines. But you know I think what I'm hoping for out of this conversation is to think you know given these documents you know where we think DLL might be a strength to the board. And where ag continues to be and will be a strength to the board when it comes to a retail end of things. So hopefully that's some good table setting. But I can appreciate how there's still some uncertainty on how we're trying to fit the puzzle together. And I like the idea of perhaps you know thinking about sort of how this is going to roll out and so much is going to be based around quality assurance. Making sure that we know where things are grown. You know and so forth. And then I could see a really nice hybridized training happening for potentially new enforcement officers. It seems like DLL definitely has the experience. I'm just hoping we can see some kind of adaptation to helping act specifically with that. Tom I see you. I think she was passing the baton over to you Tom. Sorry I didn't mean to interrupt actually. I just said other comments. You can go ahead. Oh no I'm finished. I'm really liking this idea of collaborating. I just don't know necessarily what that really entails. I need to look through that document a little bit more as well. I mean safety at retail level is going to be huge. I'm just not sure who is going to be best equipped for that. But my comments were just on Skyler's documents. Also the letter figuring in the point system which was very helpful Skyler. And I appreciate you sending that around. I was surprised by some of the level of detail because it didn't include things like lighting. And so if we were proposing Skyler or at least regulations that other states have, are other factors like video surveillance and alarm systems that I think you could easily into your point system. And maybe you could just type a comment or send something later about what your thoughts were on including some of those other measures into the point system and maybe having some of those mandatory within the point system. Yeah Tom. I know my voice is choppy. I'm going to go. So maybe most of it can come through. I think all we would simply need. Would the other states have instituted by way of email to us. I think we could take a look at it into that point system paradigm. The question is of most important value in terms of and as suited by directive or decision. Thanks Skyler. I think I caught a lot of that. I totally agree with Tom. You know we've been talking about hearing this for certain businesses. I think this point system of trying to reach a certain goal with your points to be able to be considered in compliance and successful as a retail store kind of follows a similar path to how we're talking about security and other portions of what we're trying to do here. So I really appreciate the detail there as well. Savannah, I see your hand up. Yeah. Since we're talking about the point score system, I just want to highlight the difference between alcohol and cannabis. DLL uses that system for evaluating the agency stores, i.e. the stores that we also go around and save from the liquor store. Right. Because those stores are run by private businesses. Businesses do it as agents of the state. And so the state uses that system to require that meet a certain standard. They don't use that system when it comes to evaluating all the other licensees, i.e. manufacturers and things like that. But that being said, there's no reason that we can't be thinking about a system like that. So they don't use that system when they go through their inspection. They go through the inspection of a place and they say, are you meeting all the code requirements? Right. Not necessarily a point system, but the point system helps them evaluate the agency stores and whether or not they want to renew those licenses or pick someone else as a replacement agent, et cetera, since those stores are acting on behalf of the state. But I do like the conversation we're having here that basically says we could be using this in any way. We could be using one system to think about how we evaluate when we go through an inspection of a manufacturer or are we doing an inspection of a retailer? I mean, it's a fine framework to be thinking about. So it's just food for thought for us that we think about where our offices are. Yeah, my understanding of documents, Yvonne, is that that's the score for the application. I think that's how it's titled. Yeah, but specifically, it's only the application for people who are going to be liquor stores on behalf of the state. They don't do that for any of the other stuff. But again, we can do it. Thanks, Yvonne. I agree. Chris, I know you're with us. I know you haven't been able to participate in a lot of these meetings. I also know you have some experience in this kind of regulated world. So I wanted to give you an opportunity to express any thoughts or opinions. Yeah, I'm looking at this Regulation 17 regarding not serving alcohol beverages to anybody displaying signs of intoxication. I'm kind of scratching my head how that's going to translate to cannabis. Clearly, if somebody's tremendously medicated and isn't making sense, I understand not serving that person. But a lot of cannabis people, even once in the adult rack market that are still sort of using this medicinally are using it all day every day. So what does that mean for cannabis, that regulation? Like if someone is clearly under the influence of THC, that dispensary can't sell them cannabis. I'm not sure how I'm reading that. So while I'm shaking his head, maybe you can give him some clarity. Well, I guess it's just taking with a grain of salt what things translate from one to the other. The DLL rule is about serving. So as someone in a bar who's had one too many and essentially requiring the bartender cut them off, that's very different from someone who walks into a store and buys a six-pack, or in our case walks into dispensary and purchases cannabis. It's about impairment. It's a vague statute and DLL tries to give guidance when they teach people how to interpret it. Obviously, people who are drinking are getting somewhat influenced by that behavior, but there's a border of what is too much and sometimes it's a bit more of an art than a science. But with cannabis, I think as with anything else, if a person walks into your store and they're not making sense, you might not want to serve them because you can't tell what the deal is, but that's not exactly what we're talking about with someone who is using cannabis, but additionally, recreationally, some level of background normality is different from someone who doesn't make any sense. So I'm not saying that would perfectly translate to cannabis, especially since we're talking about retail, we're not talking about licensing toto rooms where you can go hang out and consume. Maybe that's what the board is thinking about down the line. That's obviously a much different scenario. Actually, you've got to hit the nail on the head. To me, it's going to get tricky when you would have potentially an opportunity to purchase and consume on the same property. Dylan, I appreciate that you're raising that point, Chris, and Savannah, you're helping to translate. I mean, Skyler's here. I know that he's choppy, but this is also feedback for Skyler as they look to try and figure out how to translate this. So pointing out those kind of great areas where we need to adjust things accordingly to how it's going to benefit all interested parties separate from the alcohol industry is something that I know DLL is looking for feedback on. So thank you. Yeah, just following up on it, what Chris was asking, what I think Schumann answered was that it seems to me that speaking more towards over-serving in a bar, which Jim Pepper and Kyle probably know more about this than I do. But in Arizona, it's called graham shop liability with the bars. If you think reserve someone and there could be a lot of liability forward if there's an accident and injuries and death. That area of the law in cannabis, and this is nationwide, some are calling it graham shop liability. All that's going to work going forward and it's not very clear. You don't have status on over-serving, but I think Schumann is right. It's really up to the licensee holder or the business. It's in their vested interest not to over-serve because that liability can come back to you eventually and going to insurance seminars on this. That liability, how far back does that go, right? And the issue is, does it go back to the prescribing doctor? Does it go back to the client? It can flow a long way, but it all starts at that point in sale. And the retail owner and shop owner should be aware that there's not necessarily regulations nationwide on that. There's just a rule of thumb, don't over-serve. And that's going to be present in the Indian industry and in Vermont, regardless if there's regulation that comes down on it or not. Yeah, Tom, I just want to chime in. Graham shop laws are, that does exist in the state, the liability in Vermont. Not only can you sue anyone who's dependent individually or separately. So I would concur also, regulation 17, being certain who's going to make contact with over-pervious establishments, not necessarily a direct translation to the retail schema that we're probably talking about. Thanks, Skyler. And just so everybody knows, the on-site consumption lounges will be explored in our exploratory committee. I'm not sure if anybody on this call is participating in that committee specifically, but it is something the board will consider kind of like in phase two of this marketplace. And if when we get there, depending on the relationship we have with the state agency partners, I would imagine that we can explore certain parts of their regulatory interpretation that might be beneficial for what we're trying to do here. Jen, I haven't heard from you yet. I know you haven't had a whole lot of time with these documents. I know Massachusetts did things a little bit more in-house than working with other state agencies. But any first impressions on how this either looks similar or different than what you've seen in practice and on paper in Massachusetts? I think it goes back to the premise of what's your values, right? And so that is the basis of what any regulation is going to be that you put forth. We've talked a lot not only in this committee but in the marketing subcommittee that I was part of tier levels and scaling things up or down based upon how big the business is. And so if that's the value system that Vermont wants to go with, then certainly you can act in a manner and create regulations in a manner that is approved like that. It's true, the Canada's Commission in Massachusetts, we did everything in-house. I mean, I think one of the things we didn't do in the beginning was we had to contract with a hearing's officer so that someone could appeal a decision of the Canada's Commission's need. But everything was done in-house. This was our own entity. Just as with alcohol, it's housed in our alcohol beverage control commission in Massachusetts as well. So everything alcohol is in that subset. I really do think that when it comes to security, you really want to secure the product, you want to secure the person, everyone wants to make sure that this isn't diverted to children, that the product is locked up at night when people go home. Those are the basics and how a state gets to that is their own way. I think one of the difficulties has been, and not so much for Vermont, is that those of us that had legalized it early, we didn't have a playbook. We didn't have anything to go on, and so we had to create it as we did. The statute in Massachusetts is a little different. We're not required to partner with other agencies, but in our work, we took, so for instance, our packaging and labeling, we took statements that the Department of Public Health makes on certain products and put them on this product as well. We took pieces from other agencies and sort of made it work with the cannabis commission. We knew that law enforcement has an enforcement piece of this, and so they have the ability to go into a cannabis business, if they feel something wrong, things like that. But it wasn't overly obnoxious about it. So I think you're on the right track. The question is going to be, and what I've always said is, what does the big picture look like? Because all these subcommittees are looking at very, very specific issues. How is the board going to merge that work between the subcommittees? And so compliance and enforcement is dealing with the issues you're talking about today. The marketing subcommittees dealing with tiers and licensure. How does your enforcement factor into renewals when it comes down to renewals? Things like that. But I think the input has been broad enough that the board should be able to come up with systems that work for Vermont. I mean, short of things like not meeting the state lines when you're transporting, I mean, those are federal laws. Those are things you just can't get around. Well, thanks, Sharon. And I think if I think about the work of every subcommittee, but this one specifically, I think, and I know we haven't taken a general consensus or vote on every single thing that we've done, but I think one of the things that we can arrive at a consensus on right now is that this does need to have a certain tiering system within it for security. I've heard this in outdoor security, maybe less so in indoor cultivation security, but in the retail context and the transportation context that the board needs to really look at its regulations on par with how we're carrying out the market structure. So I think if there's general takeaways on what I can take back to my board members and as we start to develop an application and regulations, I think what I'm hearing is it really needs to be dependent on the size as to which you're cultivating. That honestly creates a lot more work for the board, and I'm willing 100% to wander down that road and do that work if that's the direction that we all think that this market should, how this market should look and feel trying to right size, as Jen said, the stuff from every other jurisdiction that we've seen and explored and then kind of putting the Vermont feel on it. So that's my general takeaway from the last month that I have. But you'll also have the ability to have internal processes, right? So your regulations allow you to do the overall rules and then the enforcement piece of that, whether it's an application process or an enforcement process or compliance or whatever, you can have those internal processes that over time, if they're not working, you have the ability to adjust. I mean, one of the biggest misperceptions people have is that once the regs are in place, the regs are legit in place in set and stone. In Massachusetts, we did two subsequent reg changes because some things weren't working and because our statute was brought up and it allowed us to pivot when we had to and adjust our rules to that. Vermont will have the same thing. And once you set the rules in place, your process, your internal process will be able to play out in licensing and enforcement and some of the other regulations that you're going to have. I can imagine that one of the things that's going to have to adjust is energy efficiency. If the legislature passes any energy bills because a lot of people are doing climate change, that's going to affect the cannabis business as well. And so things like that are just going to have to evolve over the next five to 10 years. Absolutely. And that specifically is something I've been working with the sustainability committee on. So I think we're on a good track there. Skylar, I see your hands up. Yeah, I just want to jump on to Jen's comments and Jen's comments. Would just be that I agree with Amber important to mention that with an evolving regulatory landscape comes that much more. So just to consider that as the rules change and grow, they're important that you can push out that in favor of retailers so that they can understand it. And Kyle, the more prescript, the more important we believe a strong regulatory inspection model is that that go unchecked or unenforced they're not really worth the paper that they're written. I must echo both a really strong education, regulatory inspection model. Thanks, Skylar. Pretty sure I caught that. Savannah? Yeah. Like Skylar, I also just want to totally agree with Jen's comment that I would essentially summarize as this is a living document, right? Regs change and laws change. And Skylar actually mentioned that earlier, and he kind of bought it up again just now, but you mentioned earlier that part of the need for education comes from the fact that the alcohol laws change every year. That's actually true. And the DLL's red is still necessarily change every year, but pretty much every year there's some alcohol on the bus bill in the legislature that passes a couple of changes. And it may be changes that were requested by industry and DLL and legislature thought they were fair or maybe the opposite direction. Maybe some of the legislators wanted or DLL wanted, but every year there's some amount of probably five or 10 things that change in alcohol law. And that ends up giving rise to, yes, that need for constant education. So yeah, to Jen's point, things change. CCB can rewrite the regs at any point if they want to. Obviously it won't do it all the time, you know, but if things aren't working, yeah, you can change them. And certain things will be big enough that CCB doesn't have power on its own to change them. They need to go to the legislature, but I'm sure that will happen. And the same way that DLL brings suggested changes to the legislature every year, CCB might do the same things, whether it's every year or not. One other thought that I just wanted to share while we're still on this topic is something else that I think DLL has done very well, which is an informal, it's not a rule at all, honestly, but it's essentially an informal rule that DLL always teaches licensees in the education seminars, which is, for years, DLL has basically given licensees permission to make up rules if it helps you deal with an unruly customer. If you're in a bar and you cut someone off and they're like, no, give me another drink, that you're able to make up a rule that is plausible so that you can blame it on the state on yourself to externalize. It's just a way of dealing with someone who's unruly. You're able to say, oh, I'm sorry, I saw you nod your head like you were falling asleep. I know you're fine, but the rules are, if I see that, I can't serve you again. I can lose my license, I'm sorry. And it's just a highlight for CCB to think about as well. It's more about culture than anything else, but I always thought that was a helpful touch that really speaks to, look, the regulations might be complicated, they might be difficult to comply with sometimes, but they still know that the regulator has your back and they're trying to find a way that enables success. Thanks, Yvonne. And I agree with everything that's been mentioned. I think we're already trying to think through how to provide the most flexibility within how we attempt to do things, recognizing that we're not going to hit the nail completely on the head first try. I think few have, and Jen already tested to that in trying to enter this marketplace. So we're going to do what we can and I like the tiering kind of system that we've all been contemplating and is trying to understand how to not be overly burdensome to the extent that we're able on our smaller participants in this market and allow them to achieve a certain standard but doing so in a way that's financially feasible for them and doing so from a point system or a combination of different security measures, so on and so forth. And this has been great. Skyler, thank you so much. I think this helped inform Skyler's thoughts on how to approach this moving forward as well and we'll continue to have conversations with DLL. I want to quickly try and pivot back to the transportation tiering system. I don't know if anybody had any final thoughts. We were very fastly running out of time last Thursday and I rushed to get a waste conversation and we had been predominantly talking about the sustainability waste context. Jen signaled that that was the appropriate place to talk about most of it and I'm appreciative of that but I wanted to give anybody any final thoughts on the internal transportation of cannabis between different stages in its life before it hits the retail shop to share them and then I want to move on to public comment and adjourn the meeting. Ashley, any final thoughts? You're the first top left on my screen, so I think you went on to pause me and then back on you. No additional comments but I do see it as a risk. I do, I do, but I just wanted to reiterate last week where talking about the plants being different hemp and THC specifically, they don't look any different and so whether we're transporting hemp or we're transporting cannabis, THC, high content THC, the plants look the same so I regretted not mentioning that last week and wanted to make sure that we take that. Thanks Ashley. Okay, I know Gina's here. I know Gina, you had mentioned that this might be something that you would consider talking the social equity committee about and I don't know, I know we're all crazy busy it's so hard to pack content into these hour long meetings but I don't know if that's a conversation that's been had in that committee or if there's a plan two before we kind of do this initial phase one wrap up. Yes, so we spoke to the subcommittee on Thursday and the things that they would be happening for social activities, for free licensees to deliver for other sectors of the industry with cultivations if they weren't able to do it on their own. So essentially they would get first shot, first crack at that kind of ancillary part of this industry if that specific company or organization can't deliver the product themselves between parts of the supply chain. Just want to make sure I understand correctly. Yes, exactly. I don't want to belabor too much if you've already got smart inquiring minds thinking about it in that committee. I think it's a good idea, interesting idea and interested to learn more on how the committee feels about that. Any final thoughts before I turn it over to public comment? Actually we don't even have anybody public in the room so we can just keep going. Our one member of the public has left the room. So any final thoughts on transportation and where we should start even as a baseline for small cultivators I guess from my perspective what would really be helpful is if I could hear, if there's one, I'm thinking maybe like a lock box of sorts I'm using a general terminology if there's one baseline security measure that our small cultivators can do that's not overly burdensome where they need to retrofit their truck with expensive equipment and so on and so forth what's the one baseline security measure that we should include for anybody no matter the size of their business. Anybody have any thoughts? Ingrid? Well I think you said it and I think locking it down comes to mind but I'm curious what Ashley and other folks think. I appreciate that Ingrid. I mean locking the vehicle I think is enough locking the product physically down inside the vehicle. One thing that's been a huge issue for us is like compliant containers that don't leach harmful chemicals or other different who knows what coming from these plastics there's been a lot of issues out west where the flower's grown organically it's tested organically and then it's tested again before it's consumed and that's where we're seeing hits for these different contaminants. We've come a long way there's definitely new packaging coming out every day but with these supply chain issues that we're already seeing with products that are plastic products it doesn't have to be plastic product I know that's one of the easiest but there's already such a shortage there's already such a difficulty in getting these things that again I just I don't want for monitors to be out of luck because we can't get compliant packaging or compliant to take locked products inside the vehicle. I think a lot of us are most concerned about keeping it at the right temperature making sure it's not that it's not a subject to heat for some long periods of time so making sure the vehicle has some kind of air conditioning or some sort of refrigeration to transport but no I mean a lot that is tricky and like what does that really do like break the windows and then there's another level of security that doesn't allow you to get the product I mean it sounds like what we're talking about for transportation like they're not even going to be able to leave the vehicle or there's going to be someone else in the car that's inside the vehicle so it seems a little bit redundant so that's kind of my comment there Thanks Ashley Any other final thoughts? I'll just agree with Ashley and you know after a couple of days since the last meeting I still kind of come out where I think I was last time locked in the car and can't be seen from outside is sufficient I don't think we need two drivers I don't think we need you know I mean I think it's totally reasonable to say you can't leave your vehicle I don't know we need that but that's at least a reasonable one to say like you know you don't go make the delivery and leave the car unattended the store comes out to you or whatever it is right you don't leave the car parked at Walmart and go on your errands I think that's fair but again if it's locked in the vehicle and not visible from outside I'm not sure how much any of those things are necessary so I really don't think that we need things beyond that I still think that building an internal locked container inside your locked car is overkill you know I still think that multiple drivers is overkill and actually I think I'm healthy for small businesses but I also still stand by it might be fair to require higher levels of rules for either larger shipment or for third-party focused IE distributors but if this is going to be built into the truck from Rhino Foods or you know Rhino Foods or whatever maybe they have different kinds of rules then a cultivator is delivering themself and or if it is a delivery from a massive 25,000 square foot suburban the Navy has different rules from you know a small less than one acre so I think the tiered approach that you mentioned Kyle doesn't make sense but I also still think at its most threshold level that locked in the car and can't be seen from the outside is already more than enough and to ask these questions earlier they're already doing it with Hem and Hem looks like a campus and we haven't heard stories of rashes of break-ins and thefts in cars when someone thinks they see a large amount of canvas in someone's cars you know so you know we already have we do have a body of knowledge and experience on which to draw Thanks about Tom and Ingrid Yeah thanks just to respond to those two comments and then I mean my main comment is I think it's still important to have them manifest and to extend the tracking the sea-to-sea tracking and tracing system throughout the vehicle I think that's mandatory in every other state I'm not advocating for two drivers although I certainly see why it makes sense in a lot of states and add security but as far as locking it and securing it I think what happens typically in other states with the theft is that when the driver this is more for delivery but transportation to the retail place if you're doing multiple ones like which is what happens in a lot of larger cities that's where the danger is when the vehicle is left unattended when the delivery is happening that's when the car becomes the target and again I know the M program has been in place but this is really a different animal when you're talking about cannabis and I think it's going to be more sought after than how many people that are on the hunt to steal someone's hemp verses because of that point for your 1% threshold that you have but I think it becomes a lot more desirable just as a cash value when you're talking about cannabis and again I don't have a criminal mind but it makes sense to me to target cannabis more than what they have and not go after the big truck that is advertising that it's in there but if you know when some regular deliveries are that's what I would go after just like I wouldn't go after if I'm going to steal something that they farm by the side of the road and I'm going to find one that's off in the dark so when it's not fenced that's the target so those are my only comments next time in grid round us out one more comment I just wonder maybe this is a bad comparison but I think there's statute already around how medical marijuana can be transported and I know it's different means I just wonder if I think there's a locked container mandate for medical marijuana I'm just noting that if we're not requiring any sort of locked and I hear what everyone is saying about it I certainly think those are good points I just wonder about that disparity yeah without being without being intimately familiar with the medical program and how you transport that product within the supply chain there is delivery from medical dispensaries to patients and they do require a lock box but I agree it should look similar depending on and that's not to say we would adopt the current medical regulation but just to bring consistency throughout both sides of the market when we do make some decisions around delivery and Ingrid I've got the medical sorry I've got the medical subcommittee in an hour so I'll confirm that and I'll let everyone know Dave? Thanks Kyle I hear what you're saying Tom but hemp has not been stolen for people's cars we have no record of that I'm unsure knowing that the plants with differences in THC but they look exactly the same I'm unsure as to how our rash of rakeins is going to occur with a bunch of people thinking that they're stealing one plant but in reality it could be another plant I just haven't heard of this happening have you heard of this happening in other states where people are looking for cannabis and they're actually getting hemp plants because they've broken into a car I know I'm not surprised that there aren't a rash or reported hemp theft now to the extent that someone might not know the difference between hemp and cannabis I don't know this is more in the context David and Shyvana have ordered for cannabis which you don't really find with hemp so there isn't the confusion that I might be knocking off a hemp delivery instead of a cannabis one they know that it's cannabis so the situation you're describing or what you're asking me to report on is yeah maybe someone mistakes hemp for cannabis I'm not aware of that either in the delivery context where it is going to be cannabis does that make sense I understand what you're saying it's just that working in the hemp field as far as regulating it it's not uncommon to see a pickup truck with a load of plants in the back but driving from farm field to farm field nobody that's not nobody is going already has a gun in their car for one thing but for another thing I just haven't heard of anyone doing that and I don't have a criminal mind either I certainly am not advocating for anybody I wouldn't think that but I just haven't heard of anybody doing this this is a real example that you're talking about and it's not something that has not happened or maybe Jen can you weigh in with hemp and people breaking into vehicles during transport thinking that it's a cannabis plant or other way around I don't think there's a lot of reports that are saying that that happens everywhere but I think not to be the cynic in the room but as the regulator you have to think about both sides you're protecting the plant and the personnel and the employee and the plants and that's why your driver is going to have a plan in place that if something does happen this is what they're going to do I think on some level the public is watching they know it's not legal yet they know it's going to be legal soon they know when Vermont is going to do their first delivery of what have you and so you have to just be thoughtful or mindful of that is that you're going to have this on the road you're going to have trucks that are driving down the street some people go to the extent to have dummy trucks there's multiple trucks that look the same so the public doesn't know where the plant is and I think on some level it's not to try to have a criminal mind although sometimes I try to think what they're thinking at the time being a psych major but what could happen you go back to those values you protect the plant and the personnel and at that point in time what do you do about that one you have some sort of level of security two you may have you know no signage on the car it's not as simple as throwing a bunch of plants in the back of your car and thinking that they know it's coming from a farm and nobody has any questions about it because at the end of the day this plant is worth more than that this plant is worth a lot more people are paying a lot of money given and I mean taxes wise and all that people are paying a lot of money to purchase this product and no amount of taxes seems to stop people from that even though there's a lot of complaints that there's high taxes it's not preventing people from buying so it's more than just hemp versus cannabis it's go back to the value system and do you protect the plant and the employee yes David just to follow I'm shocked that there's any hemp theft whatsoever or that you have any record of it just given the nature of the plant but clearly you did in early September when they knocked off that other farm like 50 stocks and 200 pounds and whatever that did happen in in Vermont and there weren't any safety regulations or anything in place and to me that's even more attenuated than the transportation of hemp that's already been harvested so it does exist even for that kind of hemp crop that was planted so I can imagine there's going to be more demand on the criminal side but it's already sitting there waiting for you to view I'd be curious if there's an insurance required insurance companies require a level of security for the car for the vehicle whichever thanks Jen thanks Tom Ingrid is your hand new or okay just a quick comment I appreciate it with Jen just added to the conversation but I also wanted to ask this is such a little thing but assuming that we have people transporting large amounts of cannabis are we going to let like have like the manifest includes some sort of official documentation so if there was like a car crash or you know a car stop for speeding and then the car is loaded up with you know how do we differentiate between the folks in the car driving large amounts of cannabis from people doing it for ill gotten you know for bad reasons versus the market here right it's a little thing but I'm just wondering what is what are we thinking about that I'm not sure that's a specific question more than just a general comment but I think that there would be you know ways if there is as Tom said if the mantis might be important to include the sale tracking component of that to make sure that folks that are still working in the illicit world transporting it trying to pass it off as illegal products you know so they don't have a complete you know defense if they are stopped to say hey I'm working legally there needs to be some way to trace it back to you know it was grown by a license holder transported by a license holder so on and so forth so I can appreciate that comment let's move on just to put a nail in the coffin on the discussion earlier I just want to clarify I think that what I was saying I think that what David and Ashley were saying was that we don't see this type of behavior in hemp overall and that someone does have that criminal mind that all of us are professing not to have for the record I don't have one either and someone who doesn't have a criminal mind doesn't know that that is hemp that was the point the point is that there have been lots of opportunities when they weren't and we haven't seen a rash of that behavior so just to put a final point on that commentary thanks Amon Ingrid is your your hand up again I gotta get used to people lowering their hands and raising it and keeping track of that so some people forget about the hand and others are really good at it so my apologies Ingrid if you have another another new comment Kyle I have to make a motion to adjourn I gotta go into my next committee meeting here so you guys can continue but I'm going to scoot out yeah I mean we're ten minutes over time this conversation has been great I think thank you everybody for your work I think I'll be in touch the board will be in touch to the full subcommittee refer to the full advisory committee into this subcommittee I hear what everybody is saying I think this tiering structure being individualistic with how we approach certain tiers of our market is a focus that this subcommittee wants the board to bring to security by speaking and we'll do our best to do that and we'll give an update to folks when we have something to update them on so I appreciate everybody's time and yeah we can adjourn the meeting and Kyle this is our last meeting until further ad hoc right correct so now I'm going to go work with our general council to turn all of this conversation into something practical and tangible so thanks everybody appreciate it